Policy Questions on Data Ownership and Access in the Smart Grid

We thank OSTP and NIST for their interest in the public’s views on the consumer interface to the Smart Grid. The transition to the Smart Grid promises great benefits for consumers, including lowered energy costs, increased usage of environmentally friendly power sources, and enhanced security against attack and outage. We are pleased to offer our thoughts on the consumer interface to the Smart Grid, and particularly our thoughts on related consumer privacy issues.

From the perspective of consumers, and particularly from the perspective of consumer privacy, we stand at a critical juncture in the development of Smart Grid. First, the emergence of increasingly sophisticated metering technologies is enabling the unprecedented collection of energy consumption data, removing a “latent structural limitation” that previously protected the revelation of intimate details about household activities. Whereas historically a consumer’s consumption data may have been collected once a month or less frequently from a traditional meter fixed to the side of a house, in the Smart Grid, sophisticated new systems will collect and record 750 to 3,000 (or more) data points a month, revealing variations in consumption that can reflect specific household activities such as sleep, work, and travel habits.